Twisted AMC & C&R Fees Gone Wrong!

VaCAP Board

VaCAP Board

Coalition of Appraisers in Virginia at Virginia Coalition of Appraiser Professionals
Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.
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Confused AMC Not Following Virginia C&R Fees Compliance Rules

This AMC is Just Wrong & Confused!

An AMC sent an appraiser the following email this morning:

“…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“

Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the same. The verbiage in the email sent to appraisers by this AMC is just WRONG!

The Virginia Real Estate Appraiser board attempted to make things easy for AMCs. On February 23, 2016 the Virginia Real Estate Appraiser Board adopted the United States Department of Veterans Affairs’ Roanoke Regional Loan Center Appraisal and Inspection Fees Schedule as a presumption of compliance. This was a gift to the AMC’s, but I guess some just don’t want to accept it.

The Virginia Real Estate Appraiser Board created a Guidance Document for AMCs and appraisers to help understand the law. VaCAP sent a copy of the Guidance Document via email and US Mail to the address of record for each AMC licensed to operate in Virginia. As AMCs did not like this clear guidance, they began to twist things around, or just ignore the parts of the legislation they did not like.

As many were still confused, or trying to avoid paying appraisers a customary and reasonable fee, the Virginia Real Estate Appraiser Board published additional guidance on DPOR’s website. They in turn sent this additional clarification along with a copy of the original Guidance Document to each AMC and appraiser licensed to operate in Virginia.

The Virginia Real Estate Appraiser Board has gone out of its way to help the AMCs. It boggles the mind why some refuse to accept it!

And here we are today… The final rules have commentary associated with them explaining each and every provision of the Dodd-Frank Act including customary and reasonable compensation to fee appraisers. Even if you don’t like the rules, we all must follow them.

Image credit flickr - Russ Sanderlin
VaCAP Board

VaCAP Board

Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.

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36 Responses

  1. GAPeach says:

    Why not name the AMC?

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  2. John Pratt says:

    CoesterVMS send me appraisal orders every week just like the one you have cited above. I never respond however I do enjoy seeing how ridiculous their request are. Many time they will call within a day or 2 with the same request, I am always polite to the caller, remember they are just the messenger and doing the job which they were hired to do. I have never accepted an assignment from them, I do not work for companies that operate like that. There are several other that are just like them. If all appraisers refused to accept assignment from them they would go out of business.

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    • Baggins - light years past form filling Baggins - light years past form filling says:

      You cannot negotiate with people who say what's mine is mine and what's yours is negotiable

      Well that’s professional and nice and all of that. I never accept the ‘it’s just my job’ argument, and immediately respond with some sort of ethics quote. There are a million of them, just pick one. My primary engagement criteria is ethic as that relates to duty.

      Ethics is knowing the difference between what you have a right to do and what is right to do

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  3. John Pratt says:

    Unfortunately in California the board here tells us they do not have the authority to enforce C & R fees. Some of the other AMCs that blast out appraisals with low fees are  Lres and Clear Capital.  I maintain a list of AMCs and a few Lender that I do not work for, for various reason, it now totals 20 companies.

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  4. Bill Johnson says:

    If anybody really cared (lenders, AMC’s, etc.), how hard would it be to say we need a USPAP compliant report and we pay at a rate equal to the VA schedule (Say $500). Per Dodd/Frank and the state of Virginia, ANY expanded scope of work requirements (above guidelines / 15 page engagement letters) should warrant higher fees. The cost approach might pay $50. Each additional comp above the mandated three might be $50 each. If my local carwash can breakdown and determine fees to the nearest dollar, and my local fast food joint can charge 10 cents for extra dipping sauces, then why are these extras (minutes to hours) for appraisers non-calculable? With state law, a competent and eager appraisal board, and a known and disclosed system to all parties, please appraisers of Virginia file by the thousands complaints of below C&R fees.

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  5. TOM D says:

    yea!!!! and $10 extra for each lash of the whip, minus the cost of bread and water that they advanced.  the few here may have escaped the plantation, but i hear the hounds.

    cruise of the damned going around in circles, but always fun to read the comments, freed man for the moment.

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  6. Baggins Baggins says:

    Jodi, just dare to go look at the amc’s web sites and such. Many of these guys offer ‘profit sharing’ return to the lenders.

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  7. TruthBeTold says:

    I’m so excited I had to tell someone. Here in L.A. for the past two weeks I’ve had the traditional low fee AMC clients begging me to take work and offering to pay whatever I want. Just got a call from AMC who last sent an appraisal assignment to me where the value range was 5,000,000 and the fee offered was $275.00 To all appraisers; this is about supply and demand. Do not go out and corral a bunch of people to be new appraisers. Your additional income will be short lived. Keep the supply/demand in balance. Your Worth, Livelihood and Value depends on it!

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    • Retired Appraiser Retired Appraiser says:

      Anyone that’s nuts enough to appraise a $5,000,000 home for a $275 fee needs to do their “profession” a favor and just kill themselves. If you don’t have the guts to do your colleagues that little favor and you’re way short on intelligence consider over the road trucking. You’ll make twice the money for 1/20th the effort and 1/1000th the liability.

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    • Baggins Baggins says:

      We’re approaching the time when there are literally more vendor managers than there are vendors themselves.  Hang tough.

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  8. John Pratt says:

    Jodi, I don’t know where you live, I live in Northern California and am semi retired. In the last month and half I have taken 12 orders, total fee  $7,900 that is an average of $658/ ea. Two of these were Mutli-family, 4-units for $1,000.ea. They were copies of each other and next door to each other and I completed them in 2 days after I inspected them. All of these were in the city limits of where I live. I can not imagine even responding to a request that came in at $259. You could make more money cleaning houses. This kind of business is available, you need to set yourself up to take advantage of this kind of business. I think you need some business guidance.

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